1.1. We/us/Fluent Forward Ltd are committed to safeguarding the privacy of our client’s, prospective clients and other website visitors and service users.
1.2. We respect the privacy of all website visitors and service users and are determined to protect the personal data of website visitors and service users. The purpose of this privacy notice is to inform you as to how we collect and process your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.
1.3. You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
2. Data controller
2.1. Fluent Forward Ltd is the data controller and responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this privacy notice). Our contact details are Fluent Forward Ltd, North View, Farrington Road, Bristol BS39 7LP. 01225 637234. For all data matters contact Matthew Todd firstname.lastname@example.org.
3. Third-party links outside of our control
3.1. Our website may include links to third-party content or websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
3.2. When you leave our website, we encourage you to read the privacy notice of every website you visit.
4. Persona Data we may Collect
4.1. Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
4.2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows
4.2.1 Identity Data, including first name/last name/ username/marital status/ title/date of birth/gender.
4.2.2 Contact Data including billing address/delivery address/email address/ telephone numbers.
4.3. We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. for example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. however, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
5. Purpose for collection of Personal Data
We use different methods to collect data from and about you including through:
Directly. You may provide us with your identity, contact or financial data for example by filling in forms or by corresponding with. This includes personal data you provide when you:
5.1.1 Apply for our products or services;
5.1.2 Subscribe to our service or publications;
5.1.3 Request marketing to be sent to you.
5.2Indirectly. We may be provided with Personal data by third parties who pass on your details to us such as:
5.2.1 When you visit our website from a link based elsewhere on the internet.
5.2.2 When you consent to a third party referring your details to us.
6. How we use your personal data
A) We will only use your personal data as and where the law allows. Most commonly, we will use your personal data in the following circumstances [processing is necessary in order to protect the vital interests of the data subject or of another natural person;
B) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
6.1.1 You have given us consent to the processing of your personal data for one or more specific purposes;
6.1.2 Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
6.1.3 Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at email@example.com
6.1.4 Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
6.2 Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. you have the right to withdraw consent to marketing at any time by contacting us at firstname.lastname@example.org
7. Purposes for which we will use your Personal Data
7.1 We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.
7.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at email@example.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
7.3Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest To register you as a new customer
a) Identity b) Contact
Performance of a contract with you To notify you of new products and services
a) Identity b) Contact
Legitimate interest To notify you of any changes to our products and services
a) Identity b) Contact
8.1 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
8.2 We have established the following personal data control mechanisms:
8.3 Promotional offers from us
8.3.1 We may use your Personal Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
8.3.2 You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you registered with us, provided us with your details when you entered a competition or registered for a promotion and, in each case, you did not opt out of receiving that marketing.
8.4 Third-party marketing
8.4.1 We will seek your express consent before we share your personal data with any company outside the [Company/ group of companies for marketing purposes.
8.5 Opting out
8.5.1 You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at firstname.lastname@example.org at any time.
8.5.2 Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product or service experience or other transactions time.
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies can be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
10. Change of purpose
10.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Matthew Todd at email@example.com.
10.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
10.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
11. WHO WE SHARE YOUR PERSONAL DATA WITH
11.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
11.1.1 External Third Parties Service Providers e.g. Google, Facebook, Squarespace
126.96.36.199 Professional advisers, acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in UK who provide consultancy, banking, legal, insurance and accounting services.
188.8.131.52 Professional advisers, acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in UK who provide consultancy, banking, legal, insurance and accounting services.
184.108.40.206 HM Revenue & Customs, regulators and other authorities, acting as processors or joint controllers based in the UK who may require reporting of processing activities in certain circumstances.
220.127.116.11 Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
18.104.22.168 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
12. DATA SECURITY
12.1 We endeavour to put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
12.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
13. DATA RETENTION
13.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
13.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
13.3 Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at firstname.lastname@example.org .
14. YOUR LEGAL RIGHTS
14.1 Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
14.1.1 The right to request a copy of the personal data which we hold about you;
14.1.2 The right to request that we correct any personal data if it is found to be inaccurate or out of date;
14.1.3 The right to request your personal data is erased where it is no longer necessary to retain such data;
14.1.4 The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
14.1.5 The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable 9i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
14.1.6 The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
14.1.7 The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
14.1.8 If you wish to exercise any of the rights set out above, please contact Matthew Todd at email@example.com .
14.2 No fee required – with some exceptions
14.2.1 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if we reasonably believe your request to be unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
13.3 What we may need from you
14.3.1 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
13.3 Time limit to respond
14.4.1 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
15. Changes to this notice and your duty to inform us of changes
15.1.2 Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
16. Queries, requests, or concerns
16.1 To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our Matthew Todd on firstname.lastname@example.org .
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